Business Organizations Should Not Take The DOJ’s Latest Voluntary Disclosure Bait

Mike Koehler of FCPA Professor argues that the DOJ's announcement last week of its “piling on policy” – in which it calls for DOD components "to appropriately coordinate with one another and with other enforcement agencies in imposing multiple penalties on a company in relation to investigations of the same misconduct” – is "bait" motivated to further entice business organizations to voluntarily disclose.